Member

These late-stage amendments also strengthen the case for our Amendment 40, which would give banks a say in determining the costs they incur in complying with the obligations imposed on them by this legislation. If this group of amendments proves anything, it is that the Government cannot reliably anticipate the real-world implications of what they are asking banks to do, nor the operational and financial impact that these tasks impose. Amendment 40 is not radical: it simply says that those carrying the cost of implementation should be part of the process that defines and accounts for that cost. If banks are to be treated as partners in the effort to tackle fraud, and not just instruments of delivery, they must be engaged meaningfully and transparently from the outset, not as an afterthought.